OT:RR:NC:N2:349

Ms. Yaping Shan
Hangzhou Joyce Household Textiles Co.,Ltd.
No.2675 Xinluo Road, Xintang Street, Xiaoshan District,
Hangzhou 311201
China

RE: Country of origin determination for pillows; 19 CFR 102.21(c)(2); tariff shift

Dear Ms. Shan:

This is in reply to your letter dated June 20, 2025, requesting a country of origin determination for pillows, which will be imported into the United States. In lieu of samples, pictures and product descriptions were provided.

FACTS:

The subject pillows have an outer shell made of 100 percent cotton woven fabric and are stuffed with either 100 percent polyester fiber or feather and down filling. You state the edges are finished with self-fabric piping that is dyed blue and measures less than 6.35 mm. The LaCrosse Loftaire Down Alternative Chamber and LaCrosse Down & Feather Chamber pillows contain a self-fabric lining that creates three separate chambers. The LaCrosse Loftaire Down Alternative Chamber pillows, 11214B-STD-White and 11214B-K-White, contain a mixture of 1.5 and 4 denier polyester fiber in the outside chambers and 4 denier polyester fiber in the middle chamber. The LaCrosse Down & Feather Chamber pillows, 11213B-STD-White and 11213B-K-White, contain down in the outside chambers and feathers in the middle chamber. The pillows are imported in Standard size, 20 × 26 inches, and King size, 20 × 36 inches. The pillows are available in the following SKU and product numbers: Name SKU# Product # LaCrosse Loftaire Down Alternative Pillow 11209A-STD-White 25DAPST01 Soft Standard LaCrosse Loftaire Down Alternative Pillow 11209A-K-White 25DAPSK02 Soft King LaCrosse Loftaire Down Alternative Pillow 11209B-STD-White 25DAPMS01 Medium Standard LaCrosse Loftaire Down Alternative Pillow 11209B-K-White 25DAPMK02 Medium King LaCrosse Loftaire Down Alternative Pillow 11209C-STD-White 25DAPFS01 Firm Standard LaCrosse Loftaire Down Alternative Pillow 11209C-K-White 25DAPFK02 Firm King LaCrosse Loftaire Down Alternative Chamber 11214B-STD-White 25DACPS01 Pillow STD LaCrosse Loftaire Down Alternative Chamber 11214B-K-White 25DACPK02 Pillow King LaCrosse Down & Feather Pillow 11205A-STD-White 25DPS01 Soft STD LaCrosse Down & Feather Pillow 11205A-K-White 25DPK02 Soft King LaCrosse Down & Feather Pillow 11205B-STD-White 25DPM01 Medium STD LaCrosse Down & Feather Pillow 11205B-K-White 25DPM02 Medium King LaCrosse Down & Feather Pillow 11205C-STD-White 25DPF01 Firm STD LaCrosse Down & Feather Pillow 11205C-K-White 25DPF02 Firm King LaCrosse Down & Feather Chamber Pillow 11213B-STD-White 25DCPS01 STD LaCrosse Down & Feather Chamber Pillow 11213B- K-White 25DCPK02 King

The manufacturing operations for the pillows are as follows:

PAKISTAN

The face, back and lining cotton fabric is woven. The fabric is exported on rolls to China.

CHINA

Polyester staple fiber is manufactured. The face, back and lining fabric is bleached and dyed. Piping is formed. The fabric is cut and sewn. The pillow is filled with Chinese-sourced 100 percent polyester fiber or feathers and down and sewn closed. The pillows are packaged and exported to the United States.

ISSUE:

What is the country of origin of the subject merchandise?

COUNTRY OF ORIGIN - LAW AND ANALYSIS:

Section 334 of the Uruguay Round Agreements Act (“URAA”) (codified at 19 U.S.C. 3592), enacted on December 8, 1994, provides the rules of origin for textiles and apparel products for purposes of the customs laws and the administration of quantitative restrictions, unless otherwise provided by the statute, entered, or withdrawn from warehouse, for consumption on or after July 1, 1996. Section 3592 has been described as Congress’s expression of substantial transformation as it relates to textile and apparel products. Section 102.21 of the Code of Federal Regulations (19 CFR 102.21), implements the URAA. The country of origin of a textile or apparel product shall be determined by the sequential application of the general rules set forth in paragraphs (c)(1) through (5) of section 102.21. See 19 CFR 102.21(c).

Paragraph (c)(1) states, “The country of origin of a textile or apparel product is the single country, territory, or insular possession in which the good was wholly obtained or produced.” As the subject merchandise is not wholly obtained or produced in a single country, territory or insular possession, paragraph (c)(1) of Section 102.21 is inapplicable.

Paragraph (c)(2) states, “Where the country of origin of a textile or apparel product cannot be determined under paragraph (c)(1) of this section, the country of origin of the good is the single country, territory, or insular possession in which each of the foreign materials incorporated in that good underwent an applicable change in tariff classification, and/or met any other requirement, specified for the good in paragraph (e) of this section:”

Paragraph (e) in pertinent part states,

The following rules shall apply for purposes of determining the country of origin of a textile or apparel product under paragraph (c)(2) of this section:

HTSUS Tariff shift and/or other requirements 9404.90 Except for goods of subheading 9404.90 provided for in paragraph (e)(2) of this section, the country of origin of a good classifiable under subheading 9404.90 is the country, territory, or insular possession in which the fabric comprising the good was formed by a fabric-making process.

The “fabric-making process” is defined in 19 CFR 102.21(b)(2) as “any manufacturing operation that begins with polymers, fibers, filaments (including strips), yarns, twine, cordage, rope, or fabric strips and results in a textile fabric.”

The subject pillows are not classified among the paragraph (e)(2) exceptions to the above tariff shift rule. As the fabric for the pillows is formed by the fabric-making process in a single country, that is, Pakistan, as per the terms of the tariff shift requirement, country of origin is conferred in Pakistan.

HOLDING:

The country of origin of the LaCrosse Loftaire Down Alternative and LaCrosse Down & Feather pillows is Pakistan in accordance with 19 CFR 102.21(c)(2). The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.

This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Kim Wachtel at [email protected].
Sincerely,

James Forkan
Acting Director
National Commodity Specialist Division